Case Document 212-3 Filed 04/11/17 Page 1 of 3 EXHIBIT 3 Case 3:17-cv-00939-WHA Document 212-3 Filed 04/11/17 Page 2 of 3 Patrick Schmidt From: Sent: To: Cc: Subject: Ismail Ramsey Monday, April 10, 2017 5:46 PM Patrick Schmidt QE-Waymo; UberWaymo; Boies Service (BSF_EXTERNAL_UberWaymoLit@bsfllp.com); Amy Craig; Miles Ehrlich RE: Deposition Subpoena to Anthony Levandowski PatrickWe object to the document requests that are part of this subpoena. They are outside the expedited discovery that Judge Alsup ordered. The Court called for document production from the parties, not from non-party deponents. Further, Anthony Levandowski plans to assert his Fifth Amendment rights with respect to any documents requests served on him. And to extent that the requests ask for a review of his personal documents and production by Friday, we believe they are unduly burdensome. We’d ask you to modify your subpoena to remove the document requests. Otherwise, we will need to meet and confer and if necessary discuss a briefing schedule on a discovery dispute/motion to modify a subpoena that complies with NDCA Civil Local Rules and Standing Orders. Regards, Izzy Ramsey Ramsey & Ehrlich LLP 510-548-3600 From: Patrick Schmidt [mailto:patrickschmidt@quinnemanuel.com] Sent: Sunday, April 9, 2017 9:00 AM To: Amy Craig; Ismail Ramsey; Miles Ehrlich Cc: QE-Waymo; UberWaymo; Boies Service (BSF_EXTERNAL_UberWaymoLit@bsfllp.com) Subject: Deposition Subpoena to Anthony Levandowski Counsel, Attached please find a deposition subpoena to Anthony Levandowski. Patrick Schmidt Associate Quinn Emanuel Urquhart & Sullivan, LLP 865 S. Figueroa Street, 10th Floor Los Angeles, CA 90017 213-443-3191 Direct 213-443-3000 Main Office Number 213-443-3100 Fax patrickschmidt@quinnemanuel.com www.quinnemanuel.com NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. 1 Case Document 212-3 Filed 04/11/17 Page 3 of 3